Practitioners and EU officials alike seem to be in agreement that the Foreign Subsidy Regulation (Regulation (EU) 2022/2560; “FSR”), which entered into force on 12 January 2023 (see our News Alert here), will have a significant effect on M&A deals. The new notification tool for transactions introduced in Articles 19 to 26 of the FSR has the potential to impose major bureaucratic burdens on deal parties by requiring them, if certain thresholds are exceeded, to notify certain transactions and...

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What does this new landmark law mean for service providers? The Digital Services Act (DSA) establishes a framework for an unprecedented level of transparency, accountability and fairness for digital services in the EU. It imposes obligations in a cascading fashion, with a base level of universal obligations and more onerous obligations applying to three specific categories of service provider. The DSA applies where recipients of a service are based in the EU, regardless of the service provider’s place of establishment....

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The Internal Revenue Service is ready, willing and able to help authorities worldwide with tax enforcement – especially with the sharing of taxpayers’ information. In Zhang v. United States, taxpayers recently appealed a decision from the U.S. District Court for the Northern District of California that denied their petition against an IRS summons for information. The summons was at the request of the Canadian tax authority; the U.S. and Canada have a bilateral tax treaty. The Ninth Circuit Court sided with the...

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The monthly newsletter gives you an overview of recent notable changes in Canadian and American immigration. Here is an overview of the most recent news as of January 31th, 2023. CANADA Prohibition on the Purchase of Residential Property by Non-Canadians Regulations As announced at the end of last year, the Act prohibiting the purchase of residential immovables by non-Canadians came into force on January 1, 2023, and so for the next 2 years. This Act is the result of collaborative work between...

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Key insights Understanding the basic framework of check-the-box regulations can help buyers and sellers identify potential U.S. income tax and reporting risks. A thorough understanding of a U.S. target’s global tax structure can allow buyers to plan for postacquisition restructuring. Accurate reporting of a U.S. target’s global tax structure can allow both buyers and sellers to negotiate tax-efficient deal structuring. Understanding the basic framework of tax classification regulations can help buyers and sellers identify potential U.S. income tax and reporting...

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